Secretary Napolitano,I am writing to you on behalf of the board of directors, and the membership of the California Pilots Association (CALPILOTS). As a non-profit volunteer organization, the California Pilots Association’s mission is as an advocate for California’s general aviation (GA) airports as well as pilot rights.

We stand together with the Aircraft Owners and Pilots Association (AOPA), the Experimental Aircraft Association (EAA), and the National Business Aircraft Association (NBAA) and more than 55,000 active pilots in California against the LASP and SD 1542-08F directives in their present form.

Our organization is very concerned that the Transportation Security Administration has not involved, until after the fact, the national general aviation organizations listed above in the creation of LASP and SD 1542-08F directives. We recognize that TSA has since created a liaison to answer questions (SD-08) – a very slow process – and frankly we are disappointed after reviewing some of the TSA’s liaison inadequate canned responses some of our membership has shared with us. We are further disappointed with the questionable secrecy surrounding SD 1542-08F, given that it directly affects the viability of GA’s private and business aviation, airport destinations, and its operation. It appears that the TSA did not want to be bothered with facts and the real world operational aspects of enforcing these ill conceived myopic security directives.

While we understand that the country’s security is the top priority, we also believe both directives to be overkill, created in the airline passenger security model, which is not appropriate for GA, especially given the smaller size and destination variability when compared to the airlines.

Frankly, neither of these directives appears to be well thought out, a result that we believe is due the TSA’s exclusion of GA in their creation. Perhaps TSA didn’t understand the value of GA’s operational experience.

In summary, we believe that each of these directives requires review and a complete revision, or withdrawal, with the direct involvement of national GA organizations listed above for the following reasons:

What is the problem the TSA is trying to solve? The TSA failed to produce evidence that general aviation presents any greater threat than boats, trains, trucks, or other modes of transportation. The significant costs in terms of lost freedoms and loss of civil liberties resulting from the TSA proposals would outweigh any additional measure of security that those proposals might bring.

How many ID’s do pilots need to carry? – General aviation is already heavily regulated in a variety of ways and pilot identities are no secret.

GA is already over burdened when it comes to costs – There appears to be little or no consideration of the huge costs associated with these directives, nor who is responsible.

GA Airports already have volunteer security programs – Pilots have long operated without incident on these airports, and it is surprising that the TSA appears to have disregarded this fact.

Lack of understanding – All general aviation pilots are covered by similar security measures as commercial pilots including vetting. The requirement for an additional check as spelled out in the SD’s are redundant.

Lack of understanding – Previously, the TSA and FAA have recognized the principle of time and distance when applying security measures at remote sections of the airport. These SD’s appear to ignore this option.

Lack of understanding – SD 1542-08F appears to ignore the differences that exist between airports, which may impose unnecessary requirements on many of the smaller airports in the country.

States and local municipalities are not in a position to implement these costly SD’s.

While the TSA has an important job to do, we question whether GA should be a priority given TSA’s limited resources to address real risks. GA pilots do not provide rides to unknown people. We do not pick up hitch hikers. We know anyone who is in our aircraft and understand how to operate on airport ramps. We follow the rules and do not need additional costly and ill conceived bureaucracy process cast upon us.

In closing we respectfully request that you direct the TSA to re-examine these security directives and allow the national general aviation organizations to work with the TSA to develop acceptable alternatives that will not impose unreasonable burdens on airports or general aviation pilots. The TSA’s idea of one size fits all does not apply to GA. We ask for your help to resolve these potential industry and business killing security directives.

The following points on each of these directives establish they are at best, ill conceived, redundant and unnecessary.

Large Aircraft Security Plan (LASP)

The LASP would expand current commercial aviation security regimes to the non-commercial aviation community. In safety regulations, those published by the Federal Aviation Administration (FAA), it is widely recognized that commercial aviation and non-commercial aviation vary significantly in mission, risk, and operational practices. These differences remain when discussing the necessity for security regulations but, through this NPRM, TSA has chosen to ignore those crucial variations.

This directive would require crew member criminal record checks, watch-list matching of passenger manifests and TSA authorization before each flight, biennial third-party audits of each aircraft operator, and new airport security measures. For the first time in American history, citizens would have to seek and receive government approval before each use of their personal vehicles to travel about the country. Current regulations for commercial aircraft of similar size (aircraft with a maximum takeoff weight [MTOW] of more than 12,500 pounds) include requirements for:

Crewmember fingerprint-based criminal history records checks (CHRCs)

Compliance with the prohibited items list (PIL)

Compliance with security directives and information circulars

On September 21, 2004, the Transportation Security Administration (TSA) issued an “interim final rule” on flight training for aliens and other designated individuals. When the interim rule was first issued, it required every person to prove his or her citizenship status (including U.S. citizens) prior to undertaking flight training in an aircraft weighing 12,500 pounds or less. Additionally, all foreign flight students were required to complete a background check process with TSA. Not only did the rule apply to flight training, but also to recurrent training under Part 61. This meant that pilots would have to prove citizenship, and aliens submit background checks, for flight reviews, instrument proficiency checks, and aircraft checkouts. – i.e., pilots are already documented.

Security Directive 1542-08F

The TSA had almost fully implemented this program before enough information about it trickled out to draw protests from individual aircraft operators and aviation associations. Consequently, the TSA agreed to bump the implementation deadline back to June 1, to allow time for further discussion. This could have been avoided had TSA included the national GA organizations.

While the TSA consulted with representatives from the airport industry prior to issuing the Security Directive (SD), no one from the general aviation community was contacted.

The directive requires an airport with one or more scheduled airline flights to institute background checks and I.D. badges for all aircraft operators and related personnel based there, including the general aviation operators. The requirement applies even if the commercial and general aviation operations are already well-segregated. Anyone who does not have the airport-issued I.D. must have an authorized airport escort. Again costs and schedule issues appear to have been ignored by the TSA. Why does a redundant process need to be implemented when we already have pilot identification in place? See below:

– The current requirement to carry a photo ID when flying as pilot in command became effective October 28, 2002. In July 2003, the FAA began issuing new, security-enhanced airman certificates to the nation’s 650,000 active pilots. The new credit card-size plastic certificates are made from high-quality composite PVC media card stock and incorporate new security features, such as a hologram of the FAA seal. According to the FAA, close to 500,000 of the new airman certificates have been issued.-

The directive applies a one-size-fits-all philosophy to airport security. However, it leaves the specifics of the security programs up to each airport. Consequently, aircraft operators would potentially have to keep track of the separate security programs for each airport they use, and would reportedly have to remain in their aircraft when visiting airports at which they are not based or for which they do not have a badge until they can be escorted from their aircraft. Clearly, this is not a workable proposal at the vast majority of airports where staff members are not present 24 hours per day, if at all.

“Pilots have long operated without incident on these airports, and it is surprising that the TSA appears to have disregarded this fact.

All general aviation pilots are covered by similar security measures as commercial pilots including vetting. The requirement for an additional check as spelled out in the SD seems redundant.

The TSA has laid out, in regulation, definitions of sensitive portions of the airport including Security Identification Display Area (SIDA), Secured Area, and Air Operations Area (AOA). Each area has differing requirements based on its sensitivity. This SD does not seem to take this into account.

Previously, the TSA and FAA have recognized the principle of time and distance when applying security measures at remote sections of the airport. This SD appears to ignore this option.

This SD also appears to ignore the differences that exist between airports, which may impose unnecessary requirements on many of the smaller airports in the country.

This SD forces aviators to acquire government approval before each flight in certain general aviation aircraft